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TMI Blog2011 (12) TMI 50X X X X Extracts X X X X X X X X Extracts X X X X ..... nt companies compete and are available in abundance. Advertisements and sales promotion are conducted to increase sale and their impact is limited and felt for a short duration. No permanent character or advantage is achieved and is palpable, unless special or specific factors are brought on record. - Expenditure are revenue in nature - decided against the revenue. - ITA NO.978/2011 - - - Dated: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le in the successive years also. There is no discussion of factual aspects, nature, type, purpose or objective behind the said expenditure. The aforesaid addition was made in the re-assessment proceedings. In the original assessment proceedings no addition on this account was made. The quantum of the expenditure is not in dispute. 3. The CIT (A) deleted the said addition as it was pointed out th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (Appeals) and the Tribunal were not of capital nature. Advertisement expenses when incurred to increase sales of products are usually treated as a revenue expenditure, since the memory of purchasers or customers is short. Advertisement are issued from time to time and the expenditure is incurred periodically, so that the customers remain attracted and do not forget the product and its qualities. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ense. Given the factual matrix, it is difficult to hold that the expenses were incurred for setting the profit earning machinery in motion or not for earning profits. 5. Harjeet Singh, Representative of the respondent has pointed out that the respondent company has never made any profits and has virtually closed down with heavy cumulative losses of more than Rs.9 crores. Even in the year in qu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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